On 20 November, a post on the Compliance & Enforcement blog from the Program on Corporate Compliance and Enforcement at the New York University School of Law says that, in the wake of the 1MDB scandal, Goldman Sachs did more than just pay fines and agree DPA, it did something that is not common: it clawed back or reduced compensation for senior executives not directly involved in the wrongdoing. It clawed back some amounts paid to senior executives during the time the misconduct was occurring, and it reduced 2020 compensation of the present top management. It says that the bank initially tried to blame rogue staff. However, in the end Goldman clawed back $76 million from the employees involved, Tim Leissner, Ng Chong Hwa, and Andrea Vella, as allowed under its contracts with them, and also clawed back from or reduced compensation of senior executive officers who were not involved. In the aggregate, the post says, all of the clawbacks, forfeitures and compensation reductions total approximately $174 million. The authors of the post say that they hope that this is a harbinger of banks’—and bankers’—greater acceptance of responsibility.
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